Yes, it is. And it's shameful. The problem with snow blocking the intake and/or freezing the fan has been documented since the car was first sold here in 2010.
A good fix would probably require a redesigned air intake. I don't understand why the Europeans don't have the problem.

Just checked mine. No foam. So what bad stuff will happen come winter?

Click to expand...

If snow/ice blocks the vents, then you'll not have any air from the outside.
If the snow on the vents melts and drips into the fan/motor, and the temperature inside the car drops below freezing, then the water in the fan will freeze and prevent the fan from turning, and thus prevent the defroster from functioning.

FWIW, I don't have the foam either, but since I live in sunny So. California, I don't have to worry (theoretically). I actually live in the mountains where we do get snow, but I also park in a garage, so it hasn't been a problem.

I'm in NOVA and do not have the foam. Made it through last winter with no problems at all. I always first cleared the vents then started the car on defrost then cleaned off all the snow. I figure any water that got down there was cleared out during the drive so there wasn't an issue.

I have lived without foam on my 2011 for the past 4 years and never had any issues with the fan/HVAC working in the winter. We had something like 170" of snow last winter and did not have a problem. The foam is nice to have, but I don't see it not being there as an indication the HVAC won't work in the winter.